ML20235H717
| ML20235H717 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 07/08/1987 |
| From: | Bird R BOSTON EDISON CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| 87-107, NUDOCS 8707150237 | |
| Download: ML20235H717 (6) | |
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Executive Offices 800 Boylston Street Boston, Massachusetts 02199 Ralph G. Bird senior Vice President - Nuclear July 08, 1987.
BECo Ltr. #87-107 U.S. Nuclear _ Regulatory Commission Attn: Document Control Desk Washington, DC 20555 3
Subject:
NRC Inspection Report 50-293/87-16 1
Dear Sir:
-Attached i_s Boston Edison Company's response to the Notice of Violation contained in the subject inspection report.
Please do not hesitate to contact me directly if you have any questions.
- de BPL/la-Attachment cc: Regional Administrator, Region I U.S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, PA 19406 Director, Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Washington, DC 20555 Senior Resident Inspector B707150237 97ayog
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ATTACHMENT 1 Boston Edison Company Docket No. 50-293 Pilgrim Nuclear Power Station License No. DPR-35 Notice of Violation Technical Specification 6.8.D states that written procedures to implement the Fire Protection Program shall be established, implemented and maintained.
Nuclear i
Organization Procedure N0P 83FPI, PNPS Fire Protection Program, states that all fire protection systems and equipment are tested, inspected, surveyed and maintained to ensure that they can perform their intended functions.
In addition:
Procedure 2.1.12, Revision 13, Daily Diesel Generator Surveillance, end monthly surveillance procedure 8.A.6, Revision 14, Fire Extinguisher Quick Checks and Maintenance Inspection, verify that the diesel generator room dry chemical i
system pressures are acceptable.
1 Procedure 2.1.12 also verifies that the B diesel generator room sprinkler supply system heat tracing temperature is acceptable.
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Procedure 8.B.22, Revision 5, Halon 1301 System-Cable Spreading Room, Attachment A, checks as-found halon storage cylinder pressures and temperatures, calculates required full charge pressure values, and assesses the
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acceptr.bility of cylinder pressure.
Contrary to the above, between January,1985 and February 1987, established fire protect',on equipment test, inspection and surveillance procedures were not properly implemented.
Specifically:
Dry chemical extinguishing system cylinder pressures were incorrectly assessed J
as acceptable during the daily and monthly performances of surveillance i
procedures 2.1.12 and 8.A.6 between December 23, 1986 and February 19, 1987.
In fact one cylinder had been below the minimum pressure limit since December 23, 1986.
Improper performance of these surveillance resulted in the failure to recognize that the system was inoperable for eight weeks.
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The B diesel generator room sprinkler supply system heat tracing temperature i
was incorrectly assessed as acceptable during performance of surveillance l
procedure 2.1.12 on numerous occasions between January, 1985 and February,
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1987.
In fact, the heat trace temperature could not be checked because the I
i temperature indicator had been missing since January 14, 1985.
Improper performance of this surveillance resulted in failure to adequately verify heat tracing operability for over two years.
Cable spreading room halon system cylinder full charge pressure values were not properly calculated during performance of surveillance procedure 8.B.22, Attachment A, on January 29, 1987. As a result, cylinder pressures were not adequately assessed.
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ALTTACHMENT X (Cont.)
Resoonse 1.
Discussion The Notice of Violation and associated Inspection Report 50-293/87-16 identifies instances between January 1985 and February 1987 where the following surveillance l
procedures were not' properly implemented:
A.
" Daily Diesel Generator Surveillance" procedure No. 2.1.12 B.
" Fire Extinguisher Quick Checks and Maintenance" procedure No. 8.A.6 C.
"Halon 1301 System - Cable Spreading Room" procedure No. 8.B.22 Procedures No. 2.1.12 and 8.A.6 require a check of the dry chemical tanks associated with the emergency diesel generators to determine if the tank pressures are within the gauge green band, 275 psig to 350 psig. On December 21, 1986, while performing the " Daily Diesel Generator Surveillance" in accordance with procedure No. 2.1.12, one of the two dry chemical fire suppression tanks in the ' A' Emergency Diesel Generator Room was identified as having a pressure less than acceptable (270 psig vs 275 psig). Maintenance Request (MR) No. 86-61-80 was issued on December 21, 1986 to correct the deficiency. The MR was inappropriately assigned a system designation associated with the diesel generator, instead of the fire protection system. As a result, the MR was not reviewed by fire protection personnel in a timely manner. Although the emergency diesel generator was not required to be operable at that time, the significance of this deficiency on system operability was not recognized. The dry chemical suppression system was required to be operable from February 6, 1987 to February 13, 1987, when irradiated fuel was being transferred to the spent fuel pool.
On February 18, 1987 while reviewing MR No.86-61-80, the Fire Prevention / Protection Officer (FPP0) recognized the significance of this deficiency relative to the requirements of the Technical Specifications. A continuous fire watch was established as a conservative measure until the dry chemical tank was reinstalled fully charged on February 27, 1987.
Our subsequent review of the events associated with the low dry chemical tank pressure, identified weaknesses in the conduct of surveillance procedures No.
2.1.12 and No. 8.A.6 as described in the Notice of Violation.
The second concern involved the fire water supply piping for the 'B' emergency diesel generator sprinkler system which includes an insulated portion exposed to outside air temperature. This section of piping is supplied with heat tracing, a temperature controller and a remote temperature indicator (TI). Surveillance procedure No. 2.1.12 includes a check when outside air temperature is less than 32 degrees F to ensure that the temperature indicated by the TI is greater than 40 degrees F.
Maintenance Request (MR) No. 85-33-4, written January 14, 1985 documented that the TI face plate was broken.
Sometime following the initiation of MR No. 85-33-4, the indicator (needle) on the TI was broken. Although the indicating needle was broken, a heat tracing operability investigation on March 24, 1987 identified that the remaining portion of the needle was observable and could identify the heat tracing temperature. Also, the heat tracing control circuit was verified operable.
The TI was replaced in accordance with MR No. 87-33-135 on April 4,1987.
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6II.ACHMENT I (Cnnt.]
The third concern identified in the Notice of Violation involved surveillance l
procedure 8.B.22 which is a monthly inspection of the cable spreading room halon system.
The halon system full charge pressure values were not properly calculated on January 29, 1987 as stated in the Notice of Violation. A subsequent surveillance was performed on March 1,1987 and its results were satisfactory.
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Corrective Steos Taken Includina Steos Taken to Avoid Future Violations j
1 Numerous corrective actions have been implemented to address the identified i
l problems in surveillance performance as well as the associated system deficiencies.
These actions are identified in a time chronology as follows:
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January 14, 1985 MR No. 85-33-4 was initiated identifying the broken gauge glass on the temperature indicator for the fire 'B' diesel generator water system heat tracing.
December 21, 1986 MR No. 86-61-80 was initiated identifying the low gauge pressure on one of the two dry chemical tanks associated with the 'A' diesel generator.
I February 18, 1987 The FPPO recognized the Technical Specification requirements associated with the low dry chemical tank pressure and initiated a continuous fire l
watch as a conservative measure.
February 27, 1987 The dry chemical tank was reinstalled fully charged and MR No. 86-61-80 was closed.
March 3, 1987 Memo No. OPS87-281 was issued to all personnel assigned to the Operations Section.
This directive identifies inconsistencies in the documentation l
of surveillance procedures No. 2.1.12 and No. 8.A.6.
The importance of proper conduct of surveillance, as well as the adverse consequences of improper performance is emphasized.
March 20, 1987 Memo No. OPS87-453 was issued to personnel assigned to the Operations Section.
This memo identifies the lessons learned from the events described in LER 50-293/87-004-00 which included weaknesses in the conduct of surveillance.
The memo describes how a number of coincidental weaknesses can result in a breakdown in the control of plant systems and specifies the operator actions and initiatives which hre necessary when discrepancies are identified.
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ATTACHMENT I (Cont.)
s March 24, 1987 A fire water supply system heat tracing operability investigation concluded that the temperature control circuit was operational and responsive to temperature changes.
No evidence was found to indicate that the heat tracing system would not have performed its design function.
April 2,1987 Procedure No. 2.1.12 was revised to improve the format of the surveillance and to correct minor technical content discrepancies. More precise i
equipment labeling information for the dry chemical tanks and heat tracing j
temperature gauge improve the ability to identify the equipment to be observed.
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Procedure No. 1.5.3 " Maintenance Request," was revised to enhance the l
Operations Supervisor (0S) function in the initial review of MR's.
The OS is now required to review the MR for impact on Technical Specification compliance and to ensure that any required additional actions are taken, such.as making notifications, initiating Failure and Malfunction Reports or fulfilling Limiting Conditions of Operation.
April 4, 1987 The TI for the fire water system heat tracing was replaced and the associated MR No. 87-33-135 was closed (MR No. 87-33-135 replaced MR No.
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85-33-4 initiated on January 14, 1985).
April 23, 1987 Procedure 8.B.22 was revised to indicate the acceptable range for Halon l
Cylinder Pressure on graph 8.B.22.F.3.
This change makes it easier to perform the required calculation for the Cable Spreading room halon system full charge pressure values.
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Date When Full Cnmoliance Was Achieved The actions required to achieve procedural compliance were completed on:
February 18, 1987 for the dry chemical suppression system when the impact of the dry chemical tank pressure was recognized and appropriate actions taken.
March 1, 1987 for the cable spreading room halon system when the calculation was reperformed correctly.
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March 24, 1987 for the fire water supply system heat tracing when the TI was verified operable.
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ATTACHMENT I (ContJ 4.
Verification of Results Achieved On June 19, 1987, a compliance check of procedure number 2.1.12 was performed by personnel assigned to the Compliance Group. All dry chemical cylinder pressures were within the operating band (green). TI-69 (Fire Water System l
Heat Tracing Temperature Gauge) was installed and operable.
The out of specification conditions observed during the compliance check were observed to have been noted on the previously conducted daily surveillance dated June 18, 1
l 1987 and appropriate corrective actions had been taken.
On June 24, 1987, a Quality Assurance review of procedure number 2.1.12 was conducted in which an operator was observed performing the surveillance.
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surveillance was. conducted in accordance with the procedures and all discrepancies were appropriately noted and acted upon.
1 The Operations Section Manager has verified through discussions with personnel assigned to the Operations Section, understanding of:
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The importance of attention to detail in fulfilling their responsibilities including the conduct and review of surveillance; I
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the relationship between out of specification conditions, system operability and compliance with Technical Specifications; and 3.
the personnel performance expectations, and the adverse consequences of improper performance.
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Additional Corrective Steos to be Taken to Assure Continued Como11anC1 He believe the corrective actions stated in section (2) above are sufficient to preclude further violations in this area.
In particular, the procedure changes, and the directive and instructional communications are intended to stimulate long term performance improvements.
The Quality Assurance Surveillance Group will continue to monitor various surveillance performed by the Operations Department.
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